1 2 3 Guidelines for Producing or Cooking Mechanically Tenderized Beef for Retail and Food Service Establishments The following guidelines are intended to control contamination by 4Escherichia coli (E. coli) O157:H7 and other pathogenic Shiga-toxin producing E. 5coli [STEC] E. coli and Salmonella species during the production, handling, or 6preparation of mechanically tenderized or injected beef at food service 7establishments and retail food stores. Since control procedures for E. coli O157:H7, 8and other pathogenic E. coli also control Salmonella and other microbiological 9pathogens, these recommended guidelines will refer specifically to the control of E. 10coli O157:H7 but will be inclusive of these additional foodborne pathogens. 11 E. coli O157:H7 is a significant public health concern in raw ground beef and the 12meat industry has implemented a variety of procedures to control this hazard. However, 13several recent E. coli O157:H7 outbreaks and resulting recalls linked to non-intact 14tenderized beef have raised concern about the safety of these products. The relatively 15recent recalls and outbreaks of non-intact tenderized beef products have also caused great 16interest in: 1) determining the potential risk these products pose to public health; and 2) 17the development of food safety preventive measures to control such risks during the 18production and preparation of non-intact beef products. 19 These guidelines have been developed for limiting contamination by E. coli 20O157:H7 during the production, handling, or preparation of mechanically tenderized beef 21(e.g., blade-tenderized beef, pinned beef) and in the production and preparation of 22injected mechanically tenderized beef. Tenderization is the process of treating whole 23muscle tissue by either a mechanical or chemical method to soften the beef tissues, 24primarily to enhance product quality. Mechanical tenderization uses blades, needles, or
25pounding devices (e.g., blade-tenderized beef, pinned beef) to soften the beef tissue. 26Other forms of tenderization use chemicals or enzymes and a mechanical processing step 27(e.g. scoring of the muscle and tumbling, needle tenderization). 28 Blade tenderized and other mechanically tenderized beef is a significant portion 29of the beef supplied to and used by the restaurant and food service industry. In 1975, it 30was estimated that over 90% of hotel, restaurant, and institutional (HRI) operations 31utilized blade tenderization (10) and in a 2003 survey conducted on behalf of the National 32Cattlemen s Beef Association, 94% of manufactures indicated they used mechanical 33tenderization to improve product quality (13). 34 Regardless of why blade tenderization is utilized, mechanically tenderized beef is 35not required to be labeled by either the USDA s Food Safety and Inspection Service or 36the Food and Drug Administration. While labeling may be seen as a value to inform a 37small proportion of consumers, labeling has never been documented as an effective way 38to appreciably affect consumer behavior broadly when it comes to cooking. All 39mechanically tenderized beef products, like all raw beef, must be labeled with safe 40handling instructions for consumers. Producers of beef injected with tenderizers or 41flavoring marinades are required to include the term (solution or tenderizer) added (or 42injected) on the principal display panel and to list the added ingredients on the 43ingredient statement of the label. 44 Scientific studies have shown a very low prevalence of E. coli O157:H7 on the 45surface of intact beef primals, ranging from 0.083 to 0.2% incidence (1). However, 46research has also demonstrated that when the product is mechanically tenderized, the 47blades or needles used in the mechanical process can transfer microorganisms from the
48surface of the beef to the interior (6, 7, 8, 10, 13). At high surface inoculation levels for 49E. coli O157:H7, after one-pass blade tenderization of beef only 3-4% of the initial 50inoculum was internalized into deeper parts/geometric center of the muscle (10, 13). In 51addition, in those studies that have quantified the surface inoculate (4 log CFU/g) versus 52those cells translocated after tenderization, very low levels of E. coli O157:H7 were 53transferred to the geometric center of the product; counts ranging from 0 to 0.83 CFU/g. 54This research indicates that adequate cooking temperatures targeted for the center of a 55product would effectively eliminate the levels of E. coli O157:H7 expected to be found in 56mechanically tenderized beef products. However, surface searing of a non-intact steak 57may not deliver enough lethality heat treatment to pathogens that may be present in the 58interior of the non-intact steak. 59 Guidelines for the production and handling of tenderized (mechanical or injected) 60meat at Federally Inspected meat processing facilities already exist. The meat processing 61guidelines are designed to prevent, eliminate or reduce contamination by E. coli O157:H7 62during the production, handling, and preparation of mechanically tenderized and injected 63beef. Recognizing that the guidelines for meat processors may not be applicable in retail 64and food service facilities, this document provides specific guidelines for the production 65and preparation of mechanically tenderized or injected beef that focus on measures to 66reduce the risk of contamination. A preventive control-based approach is reasonable 67given the expected low levels of contamination from E. coli O157:H7 in source materials 68and the current regulatory requirements on product labeling. Best practices should focus 69on controls that prevent the cross-contamination of source materials or product surfaces 70and minimize risks through application of an intervention prior to tenderization. In
71addition, the use of some of these guidelines on the receipt and holding of blade 72tenderized beef products from a manufacture assures the controls implemented in the 73production of that product are maintained at the retail or food service establishment. 74 75 Guidance for Retail Establishments That Only Repackage Beef For Sale Since mechanically tenderized beef is not required to be labeled differently from 76intact beef, the retail establishment may not be able to distinguish mechanically 77tenderized beef from intact beef cuts. Therefore, retail establishments should use a 78preventive control approach in the repackaging process and set up purchase specifications 79with their suppliers. 80 Purchase specifications should require a continuing letter of guarantee from the 81supplier that: 82 83 84 85 86 87 88 1. Assures the beef product they purchase is inspected and passed according to the Meat Inspection Act. 2. Includes a provision indicating that the product was produced following a food safety preventive control program (e.g. HACCP) in which E. coli O157:H7 is identified as a hazard likely to occur and that has a control step to eliminate the hazard or reduce it to an acceptable level. In addition to purchase requirements, the retail establishment should have in place 89control measures to reduce the risk of cross-contamination with E. coli O157:H7 and the 90proliferation of the organism in the packaging process. These controls include product 91temperature control, sanitation, and product control. 92 93
94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 1. Product Temperature Control To limit proliferation of E. coli O157: a. Verify temperature of refrigerated beef at delivery is 41ºF or less [Food Code 3-202.11(A)] b. Control cold holding temperature of product from delivery to sale by refrigerating immediately at 41ºF or less [Food Code 3-501.16(A)(2)] Maintain frozen products prior to processing at a frozen state [Food Code 3-501.11]. Temper, thaw or slack frozen beef appropriately so product does not exceed the minimum growth temperatures for E. coli O157:H7 (less than 44.6 ºF). [Food Code 3-501.12] c. Maintain temperature control in the processing and storage areas such that the product being processed does not exceed the minimum growth temperature for E. coli O157:H7 (less than 44.6 ºF) d. Rotate product on first in-first out (FIFO) or first expired first out (FEFO) basis as a good retail practice. e. Verify temperature of beef in retail case/display is 41ºF or less [Food Code 3-202.11(A)]. 2. Sanitation Program A system for monitoring the completeness and effectiveness of the sanitation procedures. a. Should be a written document that is designed to ensure sanitary conditions both before and during operations b. Should describe procedures for employee hygiene or these procedures should be described in a separate program [Food Code Chapter 2
116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 Management and Personnel; FDA Employee Health and Personal Hygiene Handbook] c. Should include proper cleaning and sanitizing procedures that describe the procedure for equipment breakdown to ensure effective and thorough cleaning and sanitizing [Food Code Chapter 4, Parts 4-6 and 4-7]. d. Verify effectiveness of the sanitizing procedures e. Prevent cross-contamination [Food Code Chapter 3, Part 3-3] f. Make the sanitation program available to appropriate employees responsible for managing or implementing these programs g. Train all employees responsible for the sanitation procedures 3. Employee Health a. A written employee health policy is recommended to be in place to exclude ill food workers from the establishment. [Food Code Annex 3, Part 2-2 Employee Health] 4. Product Traceability a. Code the product and maintain sufficient documentation to allow trace back for a time period to include any potential frozen storage that may occur prior to consumption of the finished product. 5. Labeling a. For beef products that are injected, identify any added marinade, antimicrobial ingredient, flavoring or tenderizers in the ingredient statement [Food Code 3-602.11]. Antimicrobial agents approved as
138 139 140 141 processing aides are exempted from labeling requirements (21 CFR 101.100). b. Provide required labeling for safe handling/cooking instructions [Food Code 3-201.11(F)]. 142 143 Guidance for Retail and Food Service Establishments That Tenderize or Inject Beef 144 Retail and Food Service establishments that mechanically tenderize or inject meat 145products should apply measures to reduce the risk of contamination with E. coli O157:H7 146and other pathogens during the processing of the product and particularly in the 147mechanical tenderization or injection step of the process. These preventive controls 148include, but are not limited to, product temperature control, sanitation, and product 149traceability, labeling, and interventions. It is recommended that retail and food service 150operations develop a specific written plan, such as a risk-based or HACCP plan to define 151their preventive controls. Only employees trained to implement these procedures in 152accordance with the written plan should be permitted to tenderize or inject beef products. 153Procedures for tenderizing and injecting meat should include: 154 155 156 157 158 159 160 1. Product and Solution Temperature Controls to limit proliferation of E. coli O157: a. Verify temperature of beef at delivery is 41ºF or less [Food Code 3-202.11(A)] b. Control cold holding temperature of product from delivery to sale by refrigerating immediately at 41ºF or less [Food Code 3-501.16(A)(2)]. Maintain frozen products prior to processing at a frozen state. Temper, thaw or slack frozen beef appropriately so product does not exceed the
161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 minimum growth temperatures for E. coli O157:H7 (less than 44.6 ºF) [Food Code 3-501.12] c. Maintain temperature control in the processing and storage areas such that the product being processed does not exceed the minimum growth temperature for E. coli O157:H7 (less than 44.6 ºF) [Food Code 3-501.12] d. Maintain the time and temperature relationship on all re-used or recirculated injected fluids or marinade so that they do not allow the outgrowth of E. coli O157:H7 [Food Code 3-501.16(A)(2)]. e. Rotate product on first in-first out (FIFO) or first expired first out (FEFO) basis as a good retail practice. f. Verify temperature of beef at in retail case/display is 41ºF or less [Food Code 3-501.16(A(2)] 2. Sanitation Program A system for monitoring the completeness and effectiveness of the sanitation procedures. a. Should be a written document that is designed to ensure sanitary conditions both before and during operations. b. Should describe procedures for employee hygiene or these procedures should be described in a separate program [Food Code Chapter 2 Management and Personnel; FDA Employee Health and Personal Hygiene Handbook]. c. Should include specific procedures for proper cleaning and sanitizing that include the procedures for equipment breakdown to ensure effective and
183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 200 201 202 203 204 205 thorough cleaning and sanitizing [Food Code Chapter 4, Parts 4-6 and 4-7]. d. Should include specific procedures for the disassembly, cleaning and sanitizing of the equipment used for the mechanical tenderization or injection process. These procedures are outlined below: i. Cleaning and sanitizing of equipment before operation and during operation, especially reservoirs, and piping associated with mechanical tenderizing/flavoring operations. ii. Cleaning and sanitizing procedures for blades or needles that include frequency of procedures, and methods and chemical concentrations used. e. Verify effectiveness of the sanitizing procedures f. Prevent cross-contamination [Food Code Chapter 3, Part 3-3] g. Make the sanitation program available to appropriate employees responsible for managing or implementing these programs h. Train all employees responsible for the sanitation procedures 3. Employee Health a. A written employee health policy is recommended to be in place to exclude ill food workers from the establishment [Food Code Annex 3, Part 2-2 Employee Health]. 4. Product Control a. Code the product and provide sufficient documentation to allow trace back if necessary.
206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 b. Develop purchase specifications for the suppliers to ensure that the beef to be tenderized or injected has been tested negative for E. coli O157:H7 using N=60 sampling methodology. c. Consider the use of approved antimicrobial agents as a surface treatment prior to tenderization/injecting and/or an antimicrobial agent (e.g., lactic acid) in the solution injected into the beef. A list of Safe and Suitable Antimicrobial Agents Used in the Production of Meat and Poultry Products is available from FSIS [FSIS Directive 7120.1; http://www.fsis.usda.gov/regulations_&_policies/7000_series- Processed_Products/index.asp 5. Labeling a. For beef products that are injected, identify any added marinade, antimicrobial ingredient, flavoring or tenderizers in the ingredient statement. Antimicrobial agents approved as processing aides are exempted from labeling requirements (21 CFR 101.100). b. Provide required labeling for safe handling/cooking instructions. 222 223 224 For Retail or Food Service Establishments That Cook or Thermally-Process Mechanically Tenderized or Injected Beef Steaks 225 Injected and other mechanically tenderized beef products are considered non- 226intact products. Time and temperatures for cooking non-intact products differ from those 227for cooking intact products [Food Code 3-401.11(A)(2), (C) and (D)]. Intact steaks may 228have contamination on the cut surfaces, and therefore cooking both the top and bottom to
229a surface temperature of 63 o C (145 o F) or above can inactivate pathogens on the surface. 230However, mechanically tenderized or injected steaks could have contamination below the 231surface, where the needles, blades or pins penetrate and therefore need more rigorous 232cooking. 233 The final internal temperature that must be achieved for blade-tenderized steaks, 234comminuted beef and injected beef, which are all considered non-intact, is 155 F (68 C) 235for 15 seconds or other times and temperatures combinations listed in Section 3-236401.11(A)(2) of the Food Code. When a retail or food service establishment knows that 237meat is non-intact, they should follow these cooking procedures. Those establishments 238that cook these products at a lower internal temperature, e.g., as requested by the 239consumer, must provide a consumer advisory with a disclosure and reminder [Food Code 2403-603.11]. However, this alternative may not be used by food establishments that serve 241highly susceptible populations, such as nursing homes, hospitals, schools or daycare 242facilities [Food Code 3-801.11(C)]. Additionally, the Food Code [3-401.11(D)(2)] does 243not allow under-cooked comminuted meat to be served off a children s menu. A whole- intact steak as identified by labeling or letter of guarantee may be served or 244muscle, 245offered for sale in a ready-to-eat form by cooking to a surface temperature of 145 F 246(63 C) or above and a cooked color change is achieved on all external surfaces[food 247Code 3-401.11(C)(3)]. It is best to always use a calibrated thermometer to ensure that 248correct temperature is achieved during cooking. 249 This guidance on cooking of mechanically tenderized beef is applicable to beef 250with ingredients added to induce tenderization, such as injected beef [as defined in Food
251Code 1-201.10(B)]. The guidelines provided above for cooking of mechanically 252tenderized beef also apply to injected/tenderized beef.
253 References 254(1) Anonymous. 2005. Beef industry addresses the safety of non-intact beef products. 255 Summary Report of the Non-Intact Products Processing Workshop. Coordinated 256 by the National Cattlemen s Beef Association and sponsored by the Cattlemen s 257 Beef Board, Denver. 258 259(2) Anonymous. 2005. Beef Industry Food Safety Council. Best Practices: Pathogen 260 control during tenderizing/enhancing of whole meat cuts. Available at: 261 http://www.bifsco.org/udocs/non-intact_best_practicesapril05.pdf. 262 263(3) U.S. Department of Heath and Human Services, Public Health Service, Food and 264 Drug Administration. 2009. Food Code. College Park, MD. Available at: 265 http://www.fda.gov/food/foodsafety/retailfoodprotection/foodcode/foodcode2 266 009/default.htm 267 268(4) U.S. Department of Agriculture, Food Safety Inspection Service. 2002. 269 Comparative risk assessment for intact (non-tenderized) and non-intact 270 (tenderized) beef. Docket 00-022N. U.S. Department of Agriculture, Washington, 271 D.C. Available at: 272 http://www.fsis.usda.gov/pdf/beef_risk_assess_execsumm_mar2002.pdf 273 274(5) U.S. Department of Agriculture, Food Safety Inspection Service. 2005. HACCP 275 plan reassessment for mechanically tenderized beef products. Fed. Regist. 276 70:30331 30334. 277 278(6) Johnston, R.W., M.E. Harris and A.B. Moran. 1978. The effect of mechanical 279 tenderization on beef rounds inoculated with salmonellae. J. Food Safety 1(3): 280 201-209. 281 282(7) Gill, C.O. and J.C. McGinnis. 2004. Microbiological conditions of mechanically 283 tenderized beef cuts prepared at four retail stores. Int. J. Food Microbiol. 95:95-284 102. 285 286(8) Gill, C. O., J. C. McGinnis, K. Rahn, D. Young, N. Lee, and S. Barbut. 2005. 287 Microbiological condition of beef mechanically tenderized at a packing plant. 288 Meat Sci. 69:811 816. 289 290(9) Laine, E.S., J.M. Scheftel, D.J. Boxrud, K.J. Vought, R.N. Danila, K.E. Elfering 291 and K.E. Smith. 2005. Outbreak of Escherichia coli O157:H7 infections associated 292 with nonintact blade-tenderized frozen steaks sold by door-to-door vendors. J. 293 Food Prot 68(6):1198-1202. 294 295(10) Sporing, S. B. 1999. Escherichia coli O157:H7 risk assessment for production and 296 cooking of blade-tenderized beef steaks. U.S. Department of Agriculture,
297 298 Washington, D.C. Available at: http://www.fsis.usda.gov/oppde/rdad/frpubs/01-013n/blade3.pdf. 299 300(11) Swanson, L. E., J. M. Scheftel, D. J. Boxrud, K. J. Vought, R. N. Danila, K. M. 301 Elfering, and K. E. Smith. 2005. Outbreak of Escherichia coli O157:H7 infections 302 associated with nonintact blade-tenderized frozen steaks sold by door-to-door 303 vendors. J. Food Prot. 68:1198 1202. 304 305(12) Warren, W. 2002. Characterization of E. coli O157:H7 subprimal beef cuts prior to 306 mechanical tenderization. National Cattlemen s Beef Association Research Project 307 Summary. Available at: http://www.beef.org/udocs/e.%20coli%20mech 308 %20Tenderization_Warren_6_6_03.pdf. 309 310(13) Luchansky, J.B., R. K. Phebus, H. Thippareddi, and J. E. Call. 2008. 311 Translocation of Surface-Inoculated Escherichia coli O157:H7into Beef 312 Subprimals following Blade Tenderization. J. Food Prot. 71: 2190-2197
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